Is "Conscious Avoidance" Sufficient to Establish Knowledge Under the FCPA?

The article discusses the aggressive enforcement strategy of the U.S. Department of Justice and the Securities and Exchange Commission to individuals accountable for the Foreign Corrupt Practices Act (FCPA). It highlights the anti-bribery provisions of FCPA criminalize corrupt giving or offering anything of value to a foreign official for an improper advantage. It also discusses the conviction of businessman Frederic Bourke for conspiring to pay bribes to government officials in Azerbaijan.